ML011970060
| ML011970060 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/12/2001 |
| From: | Dennig R Technical Specifications Branch |
| To: | Pietrangelo A Nuclear Energy Institute |
| Hill LA, NRR/RTSB, 415-2158 | |
| Shared Package | |
| ml011930054 | List: |
| References | |
| -RFPFR | |
| Download: ML011970060 (18) | |
Text
July 12, 2001 Mr. Tony Pietrangelo, Director Risk and Performance Based Regulation Nuclear Energy Institute 1776 I Street, N. W.
Suite 400 Washington, DC 20006-3708
Dear Mr. Pietrangelo:
Enclosed is a summary of our joint NRC/Technical Specifications Task Force (TSTF)
Owners Group meeting at the Nuclear Regulatory Commission in Rockville, Maryland on June 27, 2001. Should the TSTF have any comments or questions, please do not hesitate to contact me on 301-415-1156 or by e-mail at rld@nrc.gov.
Sincerely,
/RA/
Robert L. Dennig, Acting Chief Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 689
Enclosures:
As stated (5) cc: M. Schoppman, NEI D. Hoffman, EXCEL N. Clarkson, BWOG T. Weber, CEOG S. Wideman, WOG J. Arbuckle, WNP2 B. Woods, SONGS H. Pontious, BWROG
July 12, 2001 Mr. Tony Pietrangelo, Director Risk and Performance Based Regulation Nuclear Energy Institute 1776 I Street, N. W.
Suite 400 Washington, DC 20006-3708
Dear Mr. Pietrangelo:
Enclosed is a summary of our joint NRC/Technical Specifications Task Force (TSTF)
Owners Group meeting at the Nuclear Regulatory Commission in Rockville, Maryland on June 27, 2001. Should the TSTF have any comments or questions, please do not hesitate to contact me on 301-415-1161 or by e-mail at rld@nrc.gov.
Sincerely,
/RA/
Robert L. Dennig, Acting Chief Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 689
Enclosures:
As stated (5) cc: M. Shoppman, NEI DISTRIBUTION:
D. Hoffman, EXCEL DMatthews/FGillespie N. Clarkson, BWOG PUBLIC H. Pontious, BWROG WBeckner T. Weber, CEOG RDennig S. Wideman, WOG RTSB Members J. Arbuckle, WNP2 RTSB R/F B. Woods, SONGS ADAMS DOCUMENT NAME:C:\Program Files\Adobe\Acrobat 4.0\PDF Output\meeting summary june 27 2001.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RTSB/DRIP AC:RTSB/DRIP NAME LAHill RLDennig DATE 07/12/01 07/12/01 OFFICIAL RECORD COPY
Staff met with the Nuclear Energy Institute Technical Specification Task Force (NEI TSTF) on June 27, 2001.
The first item discussed was the Topical/TSTF/CLIIP Process, (enclosure 1). Bob Dennig explained the process of the TSB staff wanting to compile the data related to these items and walked the NEI TSTF through the handout.
Steve Wideman of WCNOC opened the discussion on establishing priorities and schedules (enclosure 2). Mr. Wideman expressed the Owner's Group (OG) concerns with what they perceive as not enough effort on staff part in completing medium and low priority TSTFs as well as a significant delay in high priority TSTFs. The OG stated that it will be submitting more than forty changes to the STS Rev. 2. Bob Dennig reassured the OG that the NRC is aware of their concerns; however, TSB cannot currently support a large number of TSTF changes and issued a Draft of current pending TSB TSTF actions, (enclosure 3). He informed the OG that TSB needs to know of additional planned STS Conversions in order to be prepared for the future workload.
Mr. Wideman discussed the OG preference on approval letters as they related to CLIIP items, specifically, TSTF-358. Mr. Dennig explained that TSB cannot provide an approval letter for TSTF-358 or any other TSTF that is going through the CLIIP process until it has gone through the public comment period. Further discussions on this topic related to the TSTF OG desire to have a chance to discuss TSB/NRC changes to TSTF prior to the TSTF being noticed for public comment, retaining as much as possible the TSTF process of a negotiated, mutually acceptable and correct resolution of the proposed TSTF changes. To the degree the schedule permits and the technical nature of TSB/NRC change warrants, TSB will follow the established TSTF process. The TSTF OG will provide information on other TSTFs they wish CLIIPed; i.e.,
TSTF-287, -283, -204, -364. The TSTF OG will be the keeper of the Master List of TSTFs and their priorities. The Top Ten CLIIP List is now defunct.
David Skeen discussed the deletion of the Monthly Operating Report (MOR). Staff is open to removing this information from the Technical Specifications with the understanding that staff can receive the information from some other source.
Kerri Kavanagh of TSB presented information regarding TSTF-372 and BWROG End State Topical Report.
TSTF-372 proposes a new LCO 3.0.8 for selected support systems delay time. The selected systems which are proposed to be added to the new LCO were removed from the standard technical specifications because they did not meet the requirements of 10 CFR 50.36. This has caused an unexpected burden on the licensees. A handout was provided to the TSTF members discussing the history of delay times for the selected support systems (enclosure 4).
Most of the proposed delay times did not match the delay times that were in the old standard technical specifications. Justification for the proposed change was only provided for the snubbers and not the other selected support systems.
TSTF-372 has been connected with initiative 7, non technical specification support system impact on technical specification LCOs. The staff will review the industry white paper on initiative 7 which is due to the staff the first week of July and evaluate the implementation
process for both initiative 7 and the TSTF. The staff will discuss their findings with the RITSTF at the next meeting on July 31, 2001. The staff will also evaluate handling snubbers as a special case since a quick review has been requested by the industry.
BWROG End State Topical Report A discussion was held with handouts (enclosure 5) on the BWROG End State Topical Report.
The staff observed that the BWROG was supposed to follow the topical report from the CEOG.
This was not the case and will make the review less timely. The BWROG report is not limited to the change of end states from Mode 4 to Mode 3. The BWROG report also proposes changes to 3.0.3 end states and elimination of reducting reactor pressure to less than or equal to 150 psig. The staff also observed that the BWROG report proposes new conditions for some of the LCOs. However, these new conditions were not discussed.
Mike Snodderly of DSSA/SPSB discussed the staff's position on possible TSTFs involving Integrated Leak Rate Testing Intervals and Hydrogen Control A discussion was held regarding possible TSTFs on extended type A leak rate test intervals and Hydrogen Control. A public meeting is scheduled for July 12, 2001 to discuss a possible risk-informed initiative to extend integrated leak rate test intervals. On June 22, 2001, BWROG topical report was received that could result in changes to generic technical specifications involving hydrogen recombiners, and hydrogen and oxygen monitors. Additional discussions were held regarding the importance of the TSTF working group to prioritize future TSTFs relative to existing TSTFs and other impending staff actions such as risk-informed rulemaking to eliminate the need for hydrogen recombiners.
Other items discussed included: 1) Revision 2 Issues - Note Alignment, TSB expressed concerns that there were inconsistencies among the utilities markups for Revision 2, therefore TSB attempted to create uniformity throughout the NUREG Series. The TSTF OG stated that it would provide TSB the most recent version of the Writer's Guide. 2) Process for posting revisions - The new Revision History Style was discussed and the format agreed upon as depicted in the May 29, 2001 letter from NEI. Additionally, it was agreed that approved incorporated TSTF would be email to the TSTF OG for review prior to being posted to the Internet. Lastly, the next TSTF meeting is tentatively scheduled for September 20, 2001.
ATTENDEES LIST NRC/TSTF OWNER'S GROUP MEETING June 27, 2001 NAME ORGANIZATION PHONE#
Mike Schoppman NEI 202-739-8011 John Arbuckle Energy Northwest/TSTF 509-37-4601 Bob Tjader NRC/NRR/RTSB 301-415-1187 Bob Dennig NRC/NRR/RTSB 301-415-1156 Leslie Hill NRC/NRR/RTSB 301-415-2158 Kerri Kavanagh NRC/NRR/RTSB 301-415-3743 Steve Wideman WCNOC/TSTF 620-364-4037 Thomas Weber PVNGS/CEOG 623-393-5764 Brian Mann Excel/TSTF 301-984-4400 Donald Hoffman Excel/TSTF 301-984-4400 Noel Clarkson Duke/BWOG/TSTF 864-885-3077 Bill Reckley NRC/NRR/DLPM 301-415-1323 Pete Hearn NRC/NRR/RTSB 301-415-1189 Mike Snodderly NRC/NRR/DSSA/SPSB 301-415-2047 Bob Giardina NRC/NRR/RTSB 301-415-3152 David Skeen NRC/NRR/DRIP 301-415-2803
MILESTONES FOR RITS INITIATIVES Initiative OG 1 - TOP 2 - TOP 3 - TOP 4 - TOP TSTF # 5 - TSTF 6 - TSTF 7 - TSTF 8 - TSTF CLIIP 9 - CLIIP 10-CLIIP 11-CLIIP OG SUB NRC RAI RES RAI NRC SER NEI SUB NRC RAI RES RAI NRC APP Y/N FRN/SE COM RES AVAIL/FRN 1 CE 5/00 C C C 6/30/01 TBD 7/31/01 8/31/01 9/14/01 10/1/01 YES 10/31/01 12/1/01 12/31/01 1 GE 3/30/01C 12/31/01 TBD YES 1 W TBD YES 1 BW TBD YES 2 ALL NA NA NA NA 358 C C C C YES 6/14/01C 8/1/01 8/15/01 3 ALL NA NA NA NA 359 C C C 9/28/01+ YES 4b ALL Concept Paper 7/1/01 5 ALL Concept Paper 7/1/01 6a ALL Pending 6b/c resolution 6b/c CE 1/01C 5/9/01C 8/15/01 9/14/01 TBD 8/15/01 9/14/01 10/15/01 11/15/01 YES 11/30/01 6b/c GE TBD YES 6b/c W TBD YES 6b/c BW TBD YES 7 ALL Concept Paper 7/1/01 8 ALL Concept Paper 2002 Enclosure 1 6/27/01
Milestones Legend:
- 3. Resolve RAIs/Issues 7. Resolve TSTF Issues & NEI submit final TSTF 10. Incorporate/address public comments
- 4. NRC Staff SER on Topical 8. RTSB approve TSTF 11. FRN Announcing availability of CLIIP/TSTF Enclosure 1 6/27/01
MILESTONES FOR RI AOT EXTENSIONS TOP/ OG/ 1 - TOP 2 - TOP 3 - TOP 4 - TOP TSTF # 5 - TSTF 6 - TSTF 7 - TSTF 8 - TSTF CLIIP 9 - CLIIP 10-CLIIP 11-CLIIP TITLE PRI OG SUB NRC RAI RES RAI NRC SER NEI SUB NRC RAI RES RAI NRC APP Y/N FRN/SE COM RES AVAIL/FRN WCAP- W C C C C 370 YES 15049 ACCUM CEOG- CE C C C C 373 YES NPSD-1168 CIV CT WCAP- W C [9/01] 411 5/29/01C YES 15376 1 RT/ESF WCAP- W [6/01] TBD 15622 AC PWR CE- CE C C C C N/A NO NPSD-1184 DC PWR CE CE C C C C 409 5/29/01C NPSD- 2 1045-A SPRAY WCAP-[] W FLUID SYS CT 6/27/01
TOP/ OG/ 1 - TOP 2 - TOP 3 - TOP 4 - TOP TSTF # 5 - TSTF 6 - TSTF 7 - TSTF 8 - TSTF CLIIP 9 - CLIIP 10-CLIIP 11-CLIIP TITLE PRI OG SUB NRC RAI RES RAI NRC SER NEI SUB NRC RAI RES RAI NRC APP Y/N FRN/SE COM RES AVAIL/FRN WCAP-[] W GEN CT WCAP-[] W DC PWR Milestones Legend:
- 3. Resolve RAIs/Issues 7. Resolve TSTF Issues & NEI submit final TSTF 10. Incorporate/address public comments
- 4. NRC Staff SER on Topical 8. RTSB approve TSTF 11. FRN Announcing availability of CLIIP/TSTF 6/27/01
MILESTONES FOR NON-RI TS CHANGES TOP/ OG/ 1 - TOP 2 - TOP 3 - TOP 4 - TOP TSTF # 5 - TSTF 6 - TSTF 7 - TSTF 8 - TSTF CLIIP 9 - CLIIP 10-CLIIP 11-CLIIP TITLE PRI OG SUB NRC RAI RES RAI NRC SER NEI SUB NRC RAI RES RAI NRC APP Y/N FRN/SE COM RES AVAIL/FRN N/A ALL N/A N/A N/A N/A 360 C C C C YES DC BAT [1]
N/A ALL N/A N/A N/A N/A 364 C C C C YES Bases [1]
Control CE- ALL C C C C 368-CE C YES NPSD- [1] 111-W 1167 332-GE RTT N/A- ALL N/A N/A N/A N/A 369 C YES Del MOR [1]
N/A ALL N/A N/A N/A N/A 372 C YES Sup Sys [1]
Inop TBD BW TBD YES PASS GE ELIM [1]
LCO AP GE4 N/A N/A N/A N/A 403 5/29/01C 3.6.2.5 3.6.3.3 2 6/27/01
TOP/ OG/ 1 - TOP 2 - TOP 3 - TOP 4 - TOP TSTF # 5 - TSTF 6 - TSTF 7 - TSTF 8 - TSTF CLIIP 9 - CLIIP 10-CLIIP 11-CLIIP TITLE PRI OG SUB NRC RAI RES RAI NRC SER NEI SUB NRC RAI RES RAI NRC APP Y/N FRN/SE COM RES AVAIL/FRN SDV GE N/A N/A N/A N/A 404 5/29/01C Actions 3.1.8Bas 2 CE CE C C C C 406 5/29/01C NPSD 911-A 2 MTC CEN-403 CE C C C C 407 5/29/01C RELAY 2 TEST CE CE C C C C 408 5/29/01C NPSD- 2 683 PTLR 3.3.1 SG CE N/A N/A N/A N/A 410 5/29/01C TRIP 3 SR ALL N/A N/A N/A N/A 400 5/29/01C 3.8.1.13 4 BASES 3.6 ALL N/A N/A N/A N/A 401 5/29/01C BASES 4 3.8.1 ALL N/A N/A N/A N/A 402 5/29/01C BASES 4 3.10.1 GE N/A N/A N/A N/A 405 5/29/01C BASES 4 6/27/01
Milestones Legend:
- 3. Resolve RAIs/Issues 7. Resolve TSTF Issues & NEI submit final TSTF 10. Incorporate/address public comments
- 4. NRC Staff SER on Topical 8. RTSB approve TSTF 11. FRN Announcing availability of CLIIP/TSTF 6/27/01
Owners Non TS support System TSTF-372 Proposed Previous Standard TS Group Delay Time Delay Time CEOG Snubbers1 [72] hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3/4.7.9)
NUREG-0212 [Containment] Structural [72] hours 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (3/4.6.1.7)
Revision 1 Integrity - Average group for atmospheric and tendon prestressing force prior to increasing less than minimum RCS temp above required2 200F for dual
[Containment] Structural [15] days N/A Integrity - Abnormal degradation other than above3 Containment Penetration [72] hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3/4.8.3.1)
Conductor Overcurrent Protective Devices4 Motor Thermal Overload [72] hours (3/4.8.3.2) no delay Devices5 time - declare affected valves inop and enter Action statement Area Temperature [72] hours 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for equipment Monitoring6 operating (3/4.7.13) see spec - need more than info than currently proposed BWOG Snubbers [72] hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3/4.7.9)
NUREG-0103 [Containment] Structural [72] hours 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (3/4.6.1.7)
Revision 3 Integrity - Average group for atmospheric and tendon prestressing force prior to increasing less than minimum RCS temp above required7 200F for dual
[Containment] Structural [15] days N/A Integrity - Abnormal degradation other than above Containment Penetration [72] hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3/4.8.3.1)
Conductor Overcurrent Protective Devices
Owners Non TS support System TSTF-372 Proposed Previous Standard TS Group Delay Time Delay Time BWOG Motor Thermal Overload [72] hours (3/4.8.3.2) no delay Devices time - declare affected valves inop and enter Action statement Area Temperature [72] hours 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for equipment Monitoring operating (3/4.7.13) see spec - need more than info than currently proposed WOG Snubbers [72] hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3/4.7.9)
NUREG-0452 [Containment] Structural [72] hours 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (3/4.6.1.7)
Revision 4 Integrity - Average group for atmospheric and tendon prestressing force prior to increasing less than minimum RCS temp above required7 200F for ice condenser
[Containment] Structural [15] days N/A Integrity - Abnormal degradation other than above Containment Penetration [72] hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3/4.8.4.1)
Conductor Overcurrent Protective Devices Motor Thermal Overload [72] hours (3/4.8.4.2) no delay Devices time - declare affected valves inop and enter Action statement Area Temperature [72] hours 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if Monitoring exceeding temp by 30 F) (3/4.7.13) see spec - need more than info than currently proposed BWR/5 Snubbers [72] hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3/4.7.5)
BWR/5 [Containment] Structural [72] hours 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (3/4.6.1.5)
Integrity - Average group tendon prestressing force less than minimum required8
Owners Non TS support System TSTF-372 Proposed Previous Standard TS Group Delay Time Delay Time NUREG-0123 [Containment] Structural [15] days N/A Revision 3 Integrity - Abnormal degradation other than above Containment Penetration [72] hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (3/4.8.3.2)
Conductor Overcurrent Protective Devices Motor Thermal Overload [72] hours (3/4.8.3.3) no delay Devices time - declare affected valves inop and enter Action statement Area Temperature [72] hours 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (3/4.7.9) and Monitoring declare the equipment in the area inoperable.
Notes:
- 1. The hydraulic snubbers are required OPERABLE to ensure that the structural integrity of the reactor coolant system and all other safety related systems are maintained during and following a seismic or other event initiating dynamic load.
2/3. This limitation ensures that the structural integrity of the containment steel vessel will be maintained comparable to the original design standards for the life of the facility. Structural integrity is required to ensure that the vessel will withstand the maximum pressure of (40) psig in the event of a (LOCA or steam line break accident).
- 4. Containment electrical penetrations and penetration conductors are protected by either deenergizing circuits not required during reactor operation or by demonstrating the OPERABILITY of primary and backup overcurrent protection circuit breakers during periodic testing.
- 5. The OPERABILITY of the motor operated valves thermal overload protection and/or bypass devices ensures that these devices will not prevent safety related valves from performing their function.
- 6. The area temperature limitations ensure that safety related equipment will not be subjected to temperatures in excess of their environmental qualification temperatures.
- 7. This limitation ensures that the structural integrity of the containment steel vessel will be maintained comparable to the original design standards for the life of the facility. Structural
integrity is required to ensure that the vessel will withstand the maximum pressure of (48) psig in the event of a (LOCA or steam line break accident). (15 psig for ice condenser plants).
- 8. This limitation ensures that the structural integrity of the containment steel vessel will be maintained comparable to the original design standards for the life of the facility. Structural integrity is required to ensure that the vessel will withstand the maximum pressure of (59) psig (reinforced concrete containment) in the event of a (LOCA) (steam line break accident). (48 psig for prestressed concrete containment with ungrouted tendons).
BWROG End State Topical Report BWR/4 Proposed Changes Scope: The assessment considered all Tech Spec end states resulting in a cold shutdown (Mode 4). The analysis then evaluated an alternate end state of remaining in hot shutdown (Mode 3) as a preferred alternative to Mode 4. Other potential preferred alternatives, such as low power operation, were outside the scope of this study.
Based on staff review - 3.0.3 end states were considered in this review although it was not specifically discussed in Introduction/Background. CEOG did not propose changes to 3.0.3 end states.
3.4.3 Safety/Relief Valves Proposed Modification: Delete Required Action B.2 and add Condition C with Required Actions C.1 and C.2 to address three or more required SRVs inoperable.
Comment: No discussion of proposed Condition C. Proposed TSTF change?
3.5.1 ECCS System (Operating)
Proposed Modification: Delete Required Action B.2. Renumber Condition H (and Required Action H.1) to Condition I (and Required Action I.1). Renumber Condition G (and Required Actions G.1 and G.2) to Condition H (and Required Actions H.1 and H.2) and remove theOR condition. Add a new Condition G that is similar to the existing Condition G but with the first condition (Two or more ADS valves inoperable) deleted and Required Action G.2 deleted.
Comment: Deleting requirement G.2 does not appear to be risk-informed. Proposed TSTF change?
3.5.3 RCIC System Proposed Modification: Delete Required Action B.2.
Comment: Doesnt meet the definition of end state as discussed in the background section of the Topical Report.
3.6.1.6 Low-Low Set (LLS) Valves Proposed Modification: Delete Required Action B.2 and add Condition C with Required Actions C.1 and C.2 to address two or more LLS valves inoperable.
Comment: No discussion of proposed Condition C. Proposed TSTF change?
Enclosure 5
3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers Proposed Modification: Modify Condition E to relate only to Condition C and delete Required Action E.2. Add Condition F with Required Actions F.1 and F.2 to address the required actions related to Conditions A, B, and D.
Comment: No discussion of proposed Condition F. Proposed TSTF change?
3.6.1.8 Suppression Chamber-to-Drywell Vacuum Breakers Proposed Modification: Delete Required Action C.2 and add Condition D with Required Actions D.1 and D.2 to address Condition B.
Comment: No discussion of proposed Condition D. Proposed TSTF change?
3.6.2.3 Residual Heat Removal Suppression Pool Cooling Proposed Modification: Delete Required Action B.2 and add Condition C with Required Actions C.1 and C.2 to address two RHR suppression pool cooling subsystems inoperable.
Comment: No discussion of proposed Condition C. Proposed TSTF change?
3.7.2 Plant Service Water System and Ultimate Heat Sink Proposed Modification: Delete Required Action E.2 and add Condition F with Required Actions F.1 and F.2 to address the remaining portion of Condition E.
Comment: No discussion of proposed Condition F. Proposed TSTF change? STS Rev. 2 different than STS Rev. 1 (so Conditions do not match).
3.7.4 Main Control Room Environmental Control System Proposed Modification: Delete Required Action B.2. Change Required Action D.1 to Be in Mode 3" with a Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Comment: STS Rev. 2 different than STS Rev. 1 (so Conditions do not match).
3.8.4 DC Sources Proposed Modification: Delete Required Action B.2.
Comment: STS Rev. 2 different than STS Rev. 1 (so Conditions do not match).
Similar comments on proposed changes to BWR/6.